This presentation covers the key practical implications from the changes in the transfer pricing rules, and actions that may be required by taxpayers including:

practical examples of how the new laws will apply, focusing on business restructures, intra-group financing and loss making subsidiaries

taxpayer profiles and "trigger transactions" impacted by the legislative changes

ATO transfer pricing audit focus areas

impact on disclosures on the International Dealing Schedule.

Author profile:

Tony Gorgas

Tony is a Partner in KPMG’s Transfer Pricing practice with over 15 years of
experience advising multinational groups on complex transfer pricing issues.
With prior commercial experience negotiating arm’s length pricing
arrangements, Tony provides a practical interpretation of the complex
technical rule book. Tony’s abilities to influence and negotiate on behalf of
clients are the cornerstone of his reputation.
Tony advises a number of the world’s leading enterprises on transfer pricing
within Australia and across the ASPAC region. He is KPMG’s leader for a
number of clients in the technology and media space.
Tony has extensive contacts within the Australian Taxation Office (ATO) and
has strong working relationships with the ATO’s Competent Authority.
Tony has successfully concluded APAs (Advance Pricing Arrangements)
involving a wide variety of transactions including large business
restructuring.
Tony successfully concluded APAs with key jurisdictions including the US,
UK, Japan and Korea, and he has valuable experience in the resolution of
Mutual Agreement Proceedings between Competent Authorities. Current at 19 July 2013

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